Registered DNFBPs (Designated Non-Financial Business or Professions
A business or profession, who is not an Authorised Person or an Auditor, and is carrying on the below business or profession in or from the DIFC, is a Designated Non-Financial Business or Profession (DNFBP);
- Real estate developers or agents which carry out transactions with a customer involving the buying or selling of real property;
- Dealers in precious metals or precious stones;
- Law firms, notary firms, or other independent legal businesses;
- Accounting, audit, or insolvency firms;
- Single Family Offices;
- Company service providers, who are not otherwise a DNFBP. A company service provider is a person that, by way of business, provides any of the following services to a customer:
- Acting as a formation agent of legal persons
- Acting as (or arranging for another person to act as) a director or secretary of a company, a partner of a partnership, or a similar position in relation to other legal persons;
- Providing a registered office, business address or accommodation, correspondence or administrative address for a company, a partnership or any other legal person or arrangement;
- Acting as (or arranging for another person to act as) a nominee shareholder for another person.
The AML Module of the DFSA Rulebook contains the Rules applicable to a DNFBP.
Tips & Traps for Becoming Registered as a DNFBP
Designated Non-Financial Business or Profession (DNFBP) must register with the DFSA. Please contact the Authorisation Enquiries Team before submitting an online application.
Please consider the following matters:
- We strongly recommend you engage with the Business Development Team of the DIFCA and the DIFCA Registrar of Companies. They will help you understand the value proposition of the DIFC, to assist your evaluation of whether a presence here will make sense for your business.
- Ensure that your business or profession falls within the definition of a DNFBP.
- If you intend to carry on a business or profession as a law firm, notary firm or independent legal business, we recommend you engage with the Government of Dubai Legal Affairs Department to help you understand any relevant approvals required for the provision of legal services in or from the DIFC.
- Read the AML Module of the DFSA Rulebook.
- Ensure you will be able to comply with relevant Rules applicable to you in the AML Module of the DFSA Rulebook upon registration. For example, ensure your proposed anti-money laundering policies and procedures reflect the requirements of the AML Module of the DFSA Rulebook and if relevant, you have identified an appropriate individual to act as the Money Laundering Reporting Officer.
Completing the Application Form
- Be as comprehensive as possible in completing the online application form. It is vital that you supply all relevant information. Openness and honesty are essential.
- The DFSA may also need to make further inquiries or seek clarification from you regarding the information provided.
- Review your application form for completeness and quality before submission.
The time taken to process your application will depend on its quality and completeness, as well as the timely submission of information and response to any requests for further clarification. The need to make the correct regulatory decision will always take precedence over meeting target timescales.
A successful application will result in the DFSA issuing you with an in principle decision letter which will allow you to complete the DIFCA Registrar of Companies process. We will then issue you with your DFSA Registration once you can demonstrate that you have successfully registered with the Registrar of Companies, and have met any other in principle conditions set out in the decision letter.
Your Obligations as a DNFBP
- The AML Module of the DFSA Rulebook contains the Rules applicable to a DNFBP.
- A DNFBP should be aware of its obligations which are contained in the AML Module of the DFSA Rulebook. It is important for a DNFBP to be familiar with which parts of the AML Module apply to them. Please read the AML Module of the DFSA Rulebook to ensure you fully understand your obligations and the requirements.
- Senior Management Responsibility: The senior management of a DNFBP is responsible for compliance with the AML Module. In carrying out their responsibilities every member of a DNFBP senior management must exercise due skill, care and diligence.
- Anti-Money Laundering Policies and Procedures: A DNFBP must establish and maintain effective Anti-Money Laundering policies, procedures, systems and controls designed to detect and prevent opportunities for money laundering in relation to its activities.
- Money Laundering Reporting Officer: A DNFBP must nominate a person as the Money Laundering Reporting Officer (MLRO). This person must be an individual who is ordinarily resident in the United Arab Emirates and must have direct access to senior management, sufficient resources, a level of seniority and independence to carry out their appointed function, and, timely and unrestricted access to information sufficient to enable them to carry out their responsibilities.
- Risk Assessments and Customer Due Diligence: A DNFBP must conduct risk assessments of their business and customers. A risk-based assessment should be a dynamic process and involving regular review, and the use of these reviews to establish the appropriate processes to match the levels of risk. The findings of these assessments should be used to determine the level of Customer Due Diligence (CDD) that should be undertaken. Generally, CDD is information and documents obtained about a customer and may assist a DNFBP to mitigate any AML risks identified with undertaking business with a customer.
- AML Training and Awareness: A DNFBP must provide AML training to all relevant employees at appropriate and regular intervals. This training should be tailored to the level of exposure and risk faced by the DNFBP to AML issues.
- Reporting Requirements to the DFSA: Registered DNFBP’s must complete an AML Return form online and submit it to the DFSA via the DFSA ePortal each year.
DNFBPs should also ensure they are familiar with any applicable requirements under Federal AML laws and regulations, including but not limited to filing AML reports with relevant Federal AML authorities.
- A DNFBP must pay the DFSA an annual fee of USD 6000.
- Please refer to the FER Module for information on the manner and timing of the payment of fees.
- DFSA Rulebook: The AML Module of the DFSA Rulebook contains the Rules that apply to a DNFBP. The AML Module has been designed to provide a single reference point for all persons and entities supervised by the DFSA for Anti-Money Laundering, Counter-Terrorist Financing and Sanctions Compliance.
- Registration Enquiries: You can direct your questions regarding our regulatory regime or registration process to Authorisation Enquiries.
- DIFCA Business Development Manager: For advice on the commercial aspects of setting up in the DIFC and for copies of its application forms.
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